GALVIN, GAUSTAD & STEIN, LLC

Galvin, Gaustad & Stein, LLC Disclosure Brochure Disclosure Brochure December 24, 2025 This Brochure provides inf ormation about the qualif ications and business practices of Galvin, Gaustad & Stein, LLC (hereinaf ter “GGS” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at (480)776-1445. The inf ormation in this brochure has not been approved or verif ied by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional inf ormation about the Firm is available on the SEC’s website at www.adviserinf o.sec.gov. GGS is an investment adviser registered with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), however, such registration does not imply a certain level of skill or training. 7377 East Doubletree Ranch Road, Suite 250, Scottsdale, Arizona 85258 | (480) 776-1445 www.GGSAdvisors.com 1  Item 2. Material Changes In this Item, GGS is required to discuss any material changes that have been made to the brochure since the last annual amendment f iled March 28, 2025. The f ollowing material changes are applicable as of the date of f iling: Item 4 has been updated to provide additional detail on Advisory Business as it relates to the integration of Clients f rom a dif f erent f irm. Item 5 has been updated to provide additional detail on Fees and Compensation as it relates to the integration of Clients f rom a dif f erent f irm. Item 10 has been updated to ref lect certain other f inancial industry activities and af f iliations . Item 3. Table of Contents 2  Item 1. Cover Page ............................................................................................................................................... 1 Item 2. Material Changes ....................................................................................................................................... 2 Item 3. Table of Contents ......................................................................................................................................... 3 Item 4. Advisory Business ...................................................................................................................................... 4 Item 5. Fees and Compensation ............................................................................................................................. 8 Item 6. Perf ormance-Based Fees and Side-by-Side Management ........................................................................... 11 Item 7. Types of Clients ....................................................................................................................................... 12 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 13 Item 9. Disciplinary Information............................................................................................................................... 18 Item 10. Other Financial Industry Activities and Affiliations ........................................................................................ 18 Item 11. Code of Ethics.......................................................................................................................................... 19 Item 12. Brokerage Practices ............................................................................................................................... 20 Item 13. Review of Accounts .................................................................................................................................. 24 Item 14. Client Ref errals and Other Compensation ................................................................................................ 25 Item 15. Custody ................................................................................................................................................... 27 Item 16. Investment Discretion ............................................................................................................................... 27 Item 17. Voting Client Securities ............................................................................................................................. 28 Item 18. Financial Inf ormation ................................................................................................................................ 28 3  Item 4. Advisory Business GGS is a registered investment adviser. Since 2010, the Firm has been providing its clients with a variety of advisory services, which include f inancial planning, pension consulting , and the management of investments. Prior to the rendering any of the f oregoing advisory services, clients are required to enter into one or more written agreements with GGS setting f orth the relevant terms and conditions of the advisory relationship (the “Agreement”). The Firm is owned by intermediate subsidiaries, MP Stein, LLC, Stephen R Galvin Asset Management, LLC, and SLG 82, LLC, each of which is owned by Mark P. Stein, Stephen R. Galvin, and Stephen L. Gaustad. As of December 31, 2024, GGS had $1,224,628,967 of assets under management, $1,211,899,404 of which was managed on a discretionary basis and $12,729,563 of which was managed on a non-discretionary basis. While this brochure generally describes the business of GGS, certain sections also discuss the activities of its Supervised Persons, which ref er to the Firm’s of f icers, partners, directors (or other persons occupying a similar status or perf orming similar f unctions), employees or any other person who provides investment advice on GGS’ behalf and is subject to the Firm’s supervision or control. Financial Planning Services GGS of f ers clients a range of f inancial planning services, which may include any or all of the f ollowing f unctions: Investment Consulting • Business Planning • Insurance Needs Analysis • Cash Flow Forecasting • • Asset Allocation • Retirement Plan Analysis • Retirement Planning • Charitable Giving • Estate Planning • Risk Management • Financial Reporting • Distribution Planning 4  In perf orming these services, GGS is not required to verif y any inf ormation received f rom the client or f rom the client’s other prof essionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such inf ormation. Clients are advised that a conf lict of interest exists if clients engage GGS to provide additional f ee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by GGS under a f inancial planning engagement or to engage the services of any such recommended prof essionals, including GGS itself . Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their f inancial situation or investment objectives f or the purpose of reviewing, evaluating or revising GGS’ previous recommendations and/or services. Retirement Plan Consulting Services GGS provides various consulting services to qualif ied employee benef it plans and their f iduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the f ollowing services: • Plan Design and Strategy • Plan Fee and Cost Analysis • Plan Review and Evaluation • Retirement Plan Committee Consultation • Executive Planning and Benef its • Fiduciary and Compliance Investment Management and Review • • Participant Education 5  As disclosed in the Agreement, certain of the f oregoing services are provided by GGS as a f iduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of GGS’ f iduciary status, the specif ic services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Investment Management Services GGS manages client investment portf olios on a discretionary or non-discretionary basis. GGS primarily allocates client assets among individual debt and equity securities and exchange -traded f unds (“ETFs”), in accordance with the investment objectives of its individual clients. On a more limited basis, the Firm allocates client assets among independent investment managers (“Independent Managers”) and options, as well as the securities components of variable annuities and variable lif e insurance contracts. In addition, GGS may also recommend that clients who qualif y as accredited investors, as def ined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge f unds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portf olios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specif ically agreed upon. Clients may also engage GGS to advise on certain investment products that are not maintained at their primary custodian, such as variable lif e insurance and annuity contracts and assets held in employer sponsored retirement plans and qualif ied tuition plans (i.e., 529 plans). In these situations, GGS directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. GGS tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portf olios are managed in a manner consistent with their specif ic investment prof iles. GGS consults with clients on an initial and ongoing basis to determine their specif ic risk tolerance, time horizon, liquidity constraints and other qualitative f actors relevant to the management of their portf olios. Clients are advised to promptly notif y GGS if there are changes in their f inancial situation or if they wish to place any limitations on the management of their portf olios. Clients may impose reasonable restrictions or mandates on the management of their accounts if GGS determines, in its sole discretion, the conditions would not materially impact the perf ormance of a management strategy or prove overly burdensome to the Firm’s management ef f orts. GGS also provides discretionary advice to clients using a model portf olio, the GGS Dynamic Growth Strategy. With respect to certain discretionary accounts, GGS selects investments including small and mid - cap companies, American Depositary Receipts (ADRs), options, mutual f unds and ETFs f or possible inclusion in the GGS Dynamic Growth Strategy. While these investments are typical of the GGS Dynamic Growth Strategy, it should be understood that there are no restrictions on specif ic stocks, industries, asset 6  classes, or geographic regions. GGS reviews the investments and allocations f or conf ormance to the GGS Dynamic Growth Strategy’s stated objectives. GGS may, f rom time to time, adjust the portf olio's risk level based on market conditions. Clients should und erstand that the GGS Dynamic Growth Strategy utilizes a long-term time horizon, aggressive return goals, high risk and limited comparison to established benchmarks like the S&P 500. Acquired Clients Certain of GGS Clients were acquired through the integration of Investment Advisor Representatives (IARs) f rom other advisory f irms into GGS and are subject to dif fering f ee schedules as f urther detailed in Item 5. These clients had arrangements with their previous f irm that include discretionary management of accounts in accordance with Investment Management Services as af orementioned but include the cost of Financial Planning which would typically be charged separately f rom the management f ee f or traditional GGS Clients. Sponsor / Manager of Wrap Program GGS is the sponsor and manager of the Galvin, Gaustad & Stein Wrap Fee Program (the “Program”), which is an arrangement where investment advisory services, brokerage execution services and custody are provided by GGS as the sponsor f or a single predetermined “wrap” f ee regardless of the number of trades completed by a client. Generally, clients participating in the Program (“Wrap Program Clients”) pay this single, all-inclusive f ee that includes money management f ees, certain transaction costs, and custodial and administrative costs. If you participate in our Program, you will pay a single f ee to us , quarterly in advance, based on the net assets under management. GGS receives a portion of the wrap f ee f or its services as the portf olio management to the Program as well as the sponsor of the Program. Transactions f or your account are executed by a securities broker-dealer via the Program. The overall cost you will incur if you particip ate in our Program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program. To compare the cost of the wrap f ee program with non-wrap f ee portfolio management services, you should consider the f requency of trading activity associated with our investment strategies and the brokerage commissions charged by broker-dealers, and the advisory f ees charged by investment advisers. Accounts managed through the Program are done so in substantially the same manner as those managed under a non-wrap arrangement. Additional inf ormation about the Program is available in GGS’ Wrap Brochure, please see Part 2A Appendix 1 of the Firm’s Form ADV. Use of Independent Managers As mentioned above, GGS may select certain Independent Managers to actively manage a portion of its clients’ assets. The specif ic terms and conditions under which a client engages an Independent Manager are set f orth in a separate written agreement between the designated Independent Manager and either GGS or the client. GGS evaluates various inf ormation about the Independent Managers it chooses to manage client portf olios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past perf ormance and risk results in relation to its clients’ individual portf olio allocations and risk exposure. GGS also takes into consideration each Independent Manager’s management style, returns, reputation, f inancial strength, 7  reporting, pricing and research capabilities, among other f actors. GGS continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the perf ormance of those accounts being managed by Independent Managers. GGS seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Item 5. Fees and Compensation GGS of f ers its services on a f ee basis, which include hourly and/or f ixed f ees, as well as f ees based upon assets under management. Financial Planning Fees GGS charges either a negotiable hourly and/or f ixed f ee to provide clients with stand -alone f inancial planning services. These f ees are largely determined by the scope and complexity of the agreed upon services, generally $300 on an hourly basis and up to $10,000 on a f ixed f ee basis. The specif ic terms and f ee structure are negotiated in advance and set f orth in the Agreement with GGS. Generally, GGS requires one-half of the f inancial planning f ee payable upon execution of the Agreement and the balance due at the time the f inancial plan is delivered, or the underlying services are rendered to completion, not to exceed six months. If the client engages GGS f or additional investment advisory services, GGS may of f set all or a portion of its f ees f or those services based upon the amount paid f or the f inancial planning services. Fees for Investment Management and Retirement Plan Consulting GGS provides investment management and/or retirement plan consulting services f or an annual f ee based on the portf olio value of the assets under the Firm’s management. The f ee varies based on the f ollowing linear f ee schedule(s): Discretionary Services PORTFOLIO VALUE ANNUAL FEE $0 - $500,000 1.25% $500,001 – $2,500,000 1.00% $2,500,001 - $5,000,000 0.80% More than $5,000,000 Negotiable Non-Discretionary Services PORTFOLIO VALUE ANNUAL FEE $0 - $500,000 1.50% $500,001 – $2,500,000 1.25% $2,500,001 - $5,000,000 1.05% More than $5,000,000 Negotiable 8  The annual f ee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by GGS on the last day of the previous billing quarter. The Firm includes cash in a clients account in determining the valuation f or billing purposes. The Firm may, in its sole discretion, not include cash in determining the f ee, especially where a client has a high percentage of cash f or reasons other than the Firm's investment management decision. If assets are deposited into or withdrawn f rom an account af ter the inception of a billing period, the f ee payable with respect to such assets is adjusted to ref lect the change in portf olio value. For the initial term of an engagement, the f ee is calculated on a pro rata basis. In the event the Agreement is terminated, the f ee f or the f inal billing period is prorated through the ef f ective date of the termination and the unearned portion is ref unded to the client. For clients who engage the Firm f or non-discretionary services, the Firm of f ers an introductory period during which the Firm applies its f ee schedule f or its discretionary services. This introductory period is generally the f irst ninety (90) days of the engagement. Clients are advised that a conf lict of interest exists f or the Firm to recommend that clients engage GGS for additional services f or compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Acquired Client Fees As ref erenced in Item 4, certain GGS Clients were acquired through the integration of IARs f rom other f irms into GGS, specif ically The Westerman Group, LLC (TWG) and are subject to dif f ering f ee schedules. Thes e clients had arrangements with their previous f irm that include discretionary management of accounts in accordance with Investment Management Services as af orementioned but include the cost of Financial Planning which would typically be charged separately f rom the management f ee f or traditional GGS Clients. For Discretionary Services including Comprehensive Financial Planning provided to f ormer Clients of TWG: PORTFOLIO VALUE ANNUAL FEE $0 - $500,000 1.60% $500,001 – $1,500,000 $1,500,001 – $2,500,000 $2,500,001 - $5,000,000 1.50% 1.25% 1.00% More than $5,000,000 Negotiable The annual f ee is prorated and charged quarterly, in arrears, based upon the market value of the assets being managed by GGS on the last day of the previous billing quarter. The Firm includes cash in a clients account in determining the valuation f or billing purposes. The Firm may, in its sole discretion, not include cash in determining the f ee, especially where a client has a high percentage of cash f or reasons other than the Firm's investment management decision. 9  Fee Discretion GGS, in its sole discretion, may negotiate to charge a lesser f ee based upon certain criteria, such as anticipated f uture earning capacity, anticipated f uture additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities. Additional Fees and Expenses In addition to the advisory f ees paid to GGS, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks, and other f inancial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions, transaction f ees, custodial f ees, f ees charged by the Independent Managers, charges imposed directly by a mutual f und or ETF in a client’s account, as disclosed in the f und’s prospectus (e.g., f und management f ees and other f und expenses), def erred sales charges, odd -lot dif f erentials, transf er taxes, wire transf er and electronic f und f ees and other f ees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Fee Debit Clients provide GGS with the authority to directly debit their accounts f or payment of the Firm’s investment advisory f ees. The Financial Institutions that act as qualif ied custodian f or client accounts have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to GGS. Alternatively, clients may elect to have GGS send them an invoice f or direct payment. Account Additions and Withdrawals Clients may make additions to and withdrawals f rom their account at any time, subject to GGS’ right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transf erred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to GGS, subject to the usual and customary securities settlement procedures. However, GGS designs its portf olios as long -term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. GGS may consult with its clients about the options and implications of transf erring securities. Clients are advised that when transf erred securities are liquidated, they may be subject to transaction f ees, f ees assessed at the mutual f und level (i.e. contingent def erred sales charge) and/or tax ramif ications. 10  Item 6. Performance-Based Fees and Side-by-Side Management GGS does not provide any services f or a perf ormance-based f ee (i.e., a f ee based on a share of capital gains or capital appreciation of a client’s assets). 11  Item 7. Types of Clients GGS provides its services to individuals, trusts, pension and prof it sharing plans, and corporations and other business entities. Minimum Portfolio Size As a condition f or starting and maintaining an investment management relationship, GGS imposes a minimum portf olio size of $500,000. The Firm, in its sole discretion, may accept clients with smaller portf olios based upon certain criteria, such as anticipated f uture earning capacity, anticipated f uture additional assets, dollar amount of assets to be managed, related accounts, account co mposition, pre- existing client relationships, account retention and pro bono activities. GGS only accepts clients with less than the minimum portf olio size if , in the sole opinion of the Firm, the smaller portf olio size will not result in a substantial increase of investment risk beyond the client’s identif ied risk tolerance. GGS may aggregate the portf olios of f amily members to meet the minimum portf olio size. 2 12  Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies GGS has developed a propriety security selection methodology based primarily on f undamental analysis. Fundamental analysis involves an evaluation of the f undamental f inancial condition and competitive position of a particular f und or issuer. For individual equities, GGS’ process typically involves three primary components: (1) A stock screening process based on academic studies and GGS research, which highlights quantitative metrics that historically have led to long-term, risk-adjusted outperf ormance. Examples include f avoring stocks with low volatility, consistent dividend growth, strong prof itability and solid earnings quality. (2) A company-specific discounted cash f low model to determine our f air value estimate f or a company’s stock price based on a combination of GGS and sell-side consensus f orecasts. GGS believes the best valuation method is to discount a company’s expected f uture cash f lows at an appropriate discount rate based on risk. (3) A deep - dive qualitative analysis of the company f ocusing on items such as: i) competitive advantages that support revenue growth, margins and returns on capital; ii) shareholder- f riendly management teams with strong track records; iii) red f lags such as high customer, supplier, geographic or shareholder concentration, lawsuits, debt or accounting issues; and iv) recent news and upcoming potential catalyst events. Stocks that look most f avorable to GGS based on all three of the above selection tests have a high likelihood of being purchased in client portf olios, subject to individual client suitability, cash availability and portf olio risk constraints. For individual bond selection, GGS f ocuses its research on the f inancial health of the issuer including debt levels, debt covenants, payment schedules and GGS’ belief in the company’s ability to repay the particular bond the Firm is buying f or clients. GGS primarily invests in the individual company debt of investment grade corporations. GGS attempts to maximize yield while minimizing both interest rate and credit risk, as well as making sure the security f its in the client’s overall portf olio f rom a risk and diversif ication standpoint. For mutual f unds and ETFs, GGS’ research process typically involves an analysis of the security’s expense ratio, total assets and trading liquidity as well as the issuer’s management team, style drif t, past perf ormance, reputation and f inancial strength. A substantial risk in relying upon f undamental analysis is that while the overall health and position of a company or f und may be good, evolving market conditions may negatively impact the security. GGS develops individual investment strategies based upon each client’s specif ic risk prof ile and investment objectives. As discussed above, the Firm employs an analytical approach based upon f undamental analysis. GGS generally seeks to target individual stocks and bonds, and ETFs, which are designed to achieve each client’s stated goals. 13  Risks of Loss General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear potential losses. Past perf ormance is in no way an indication of f uture results. Over time, assets will f luctuate and be worth more or less than the initial invested amount. Depending on the investment type, dif f ering risk levels will exist. GGS cannot of f er any guarantees or promises that a client's f inancial goals and objectives will be met. GGS does not represent or guarantee that any services provided or analysis metho ds can predict f uture results, successf ully identif y market tops or bottoms, or insulate clients f rom losses due to market corrections or declines. Clients are advised that certain assumptions may be made regarding interest and inf lation rates, past trends, and the perf ormance of the market and economy. There is no guarantee of client account f uture perf ormance or any level of perf ormance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual perf ormance shown will lead to expected results or perf orm in any predictable manner. When evaluating risk, f inancial loss may be viewed dif ferently by each client and may depend on many dif f erent risks, each of which may af f ect the probability and magnitude of potential losses. The f ollowing list of investment risks, which is not all-inclusive, is provided f or caref ul consideration by a prospective client bef ore retaining our services or contemplating investments in general. (Please note: The below items are presented not in order of importance.) Market Risks Market risk involves the possibility that an investment's current market value will f all because of a general market decline, reducing the investment value regardless of the issuer's operational success or f inancial condition. The price of a security, optio n, bond, or mutual f und can drop due to tangible and intangible events and situations. External f actors cause this risk, independent of a security's underlying circumstances. The prof itability of a signif icant portion of GGS’ recommendations may depend to a great extent upon correctly assessing the f uture course of price movements of stocks and bonds. There can be no assurance that GGS will be able to predict those price movements accurately. Bank Obligations Risks Bank Obligations including bonds and certif icates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other f inancial institutions are af f ected by interest rates and may be adversely af f ected by downturns in the US and f oreign economies or banking regulations changes. Bankruptcy Risks Bankruptcy of a broker or custodian could causes excessive costs or loss of investor f unds. If a broker with which the Advisor has an account becomes insolvent or bankrupt, the Advisor may be unable to recover all or even a portion of the assets maintained by clients with that broker. Similarly, if a custodian housing a client’s securities or other assets becomes bankrupt or insolvent, the client may be unable to recover all or even a portion of the assets held by the custodian. 14  Conflicts of Interest Risks In administering client portf olios and f inancial reporting, advisers f ace inherent interest conf licts. They mitigate these conf licts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client’s interest is always held above that of the f irm and its Associates. Cybersecurity Risks GGS and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data f rom both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage or interruption f rom computer viruses, network f ailures, computer and telecommunications f ailures, inf iltration by unauthorized persons and security breaches, usage errors by their respective prof essionals, power outages and catastrophic events such as f ires, tornadoes, f loods, hurricanes and earthquakes. A cybersecurity breach could expose both GGS and its clients’ accounts to substantial costs (including, without limitation, those associated with f orensic analysis of the origin and scope of the breach, i ncreased and upgraded cybersecurity, identity thef t, unauthorized use of proprietary inf ormation, litigation, adverse investor reaction, the dissemination of conf idential and proprietary inf ormation and reputational damage), civil liability as well as regulatory inquiry and/or action. While GGS has established a business continuity plan in the event of , and risk management strategies, systems, policies and procedures to seek to prevent, cybersecurity breaches, there are inherent limitations in such plans, strategies, systems, policies and proced ures including the possibility that certain risks have not been identif ied. Furthermore, GGS cannot control the cybersecurity plans, strategies, systems, policies and procedures put in place by other service providers and/or the issuers in which GGS invests. Artificial Intelligence Engines and Machine Learning (collectively “AI”) AI is used as an umbrella term that encompasses a broad spectrum of dif f erent technologies and applications. GGS def ines AI as computer systems able to perf orm tasks that normally require human intelligence, such as visual perception, speech recognition, d ecision-making, and translation between languages, more commonly known as generative AI. As part of our investment management process the Firm uses AI, in part but not exclusively, as part of its investment, research, clerical or due diligence processes. When relying on AI there are certain risks involved, including data quality, copyright and trade secret violations, conf identiality breaches, unauthorized access or malware risks, insider trading, breach of contract, cybersecurity, and privacy law violatio ns. Data inputs and outputs are assessed and evaluated for data integrity, however, there is no assurance of accuracy, and your account may be negatively af f ected. Diversification and Concentration Concentrating investments in a single industry may result in losses due to f actors that af f ect an entire industry. Each particular industry or sector may be af f ected by unique risks, and the value of investments in a particular industry will dif fer f rom the value of the overall stock market. Fluctuations in specif ic market sectors are of ten more extreme than f luctuations in the overall market. Theref ore, concentrating investments in a single industry exposes an investor to the risk that a single set of events or circumstances will decrease the value of the investor’s overall portf olio. 15  Inflation & Interest Rate Risk Security prices and portf olio returns will likely vary in response to inf lation and interest rates changes. Inf lation causes f uture dollars to be worth less and may reduce the purchasing power of a client's f uture interest payments and principal. Inf lation also generally leads to higher interest rates which may cause the value of many types of f ixed-income investments to decline. Equity Equity Investment Risk generally ref ers to buying shares of stocks by an individual or f irm in return for receiving a f uture payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Mutual Funds and ETFs An investment in a mutual f und or ETF involves risk, including the loss of principal. Mutual f und and ETF shareholders are necessarily subject to the risks stemming f rom the individual issuers of the f und’s underlying portf olio securities. Such shareholders are also liable f or taxes on any f und-level capital gains, as mutual f unds and ETFs are required by law to distribute capital gains in the event they sell securities for a prof it that cannot be of f set by a corresponding loss. Shares of mutual f unds are generally distributed and redeemed on an ongoing basis by the f und itself or a broker acting on its behalf . The trading price at which a share is transacted is equal to a f und’s stated daily per share net asset value (“NAV”), plus any shareholders f ees (e.g., sales loads, purchase f ees, redemption f ees). The per share NAV of a mutual f und is calculated at the end of each business day, although the actual NAV f luctuates with intraday changes to the market value of the f und’s holdings. The trading prices of a mutual f und’s shares may dif f er signif icantly f rom the NAV during periods of market volatility, which may, among other f actors, lead to the mutual f und’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily f or indexed based ETFs and more f requently f or actively managed ETFs. However, certain inef f iciencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market f or such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Theref ore, if a liquid secondary market ceases to exist f or shares of a particular ETF, a shareholder may have no way to dispose of such shares. Bonds – Inflation Risk. Inf lation risk results f rom the variation in the value of cash f lows f rom a security due to inf lation, as measured in terms of purchasing power. For example, if a client purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inf lation is 6%, then the purchasing power of the cash f low has declined. For all but inf lation linked bonds, adjustable bonds or f loating rate bonds, clients are exposed to inf lation risk because the interest rate the issuer promises to make is f ixed f or t he lif e of the security. To the extent that interest rates ref lect the expected inf lation rate, f loating rate bonds have a lower level of inf lation risk. Corporate Bond Risks Corporate debt securities (or "bonds") are typically saf er investments than equity securities, but their risk 16  can also vary widely based on: the f inancial health of the issuer; the risk that the issuer might def ault; when the bond is set to mature; and, whether or not the bond can be "called" bef ore maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Options Risks Options allow investors to buy or sell a security at a contracted strike price (not necessarily the current market price) at or within a specif ic period of time. Clients may pay or collect a premium f or buying or selling an option. Investors transact in options to either hedge against potential losses or to speculate on the perf ormance of the underlying securities. Option transactions involve inherent risks, including the partial or total loss of principal in the event that the value of the underlying security or index does not increase or decrease to the level of the respective strike price. Holders of option contracts are also subject to def ault by the option writer which may be unwilling or unable to perf orm its contractual obligations. Use of Independent Managers Risks GGS may recommend the use of Independent Managers. In these situations, GGS continues to do ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, GGS generally may not have the ability to supervise the Independent Managers on a day -to-day basis. 17  Item 9. Disciplinary Information GGS has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations Certain of GGS’s Management Persons are dual registered with another state registered investment advisor. GGS has two IARs, David G. Millet and Vincent E. Westerman, who are dually registered with GGS and The Westerman Group, LLC, (TWG) an Ohio state Registered Investment Advisor. The purpose of this dual registration is to f acilitate the transf er of clients f rom TWG to GGS as part of a planned integration of the two f irms. The dual registration is set up so that Mr. Millet and Mr. Westerman can ef f ectively manage each f irm’s respective Client assets while Client accounts are moved f rom TWG to GGS. This process is expected to be completed by April 1, 2026. There is a conf lict in that these IARs will be collecting a management f ee f rom Clients that currently have an advisory relationship with TWG as well as Clients who have signed new advisory agreements with GGS. Both IARs will also be responsible f or f ollowing each respective f irm’s code of ethics and reporting requirements. GGS believes that it has remediated these conf licts by having a planned transition timeline f or existing Clients of TWG to sign new advisory agreements with GGS. Af ter the transition of all TWG Clients to GGS, TWG will withdraw its registration f rom the state of Ohio and decommission TWG. At such point, they will be IARs exclusively to GGS. Since TWG Clients will eventually be GGS Clients, there is a presumption that GGS and TWG have a vested interest in maintaining their f iduciary duties to each Client wit hout f avoring either TWG or GGS Clients. Both f irm’s Clients will either continue to or have access to GGS’s investment program. Each f irm will be responsible f or overseeing its code of ethics. There is not expected to be any conf lict in reporting requirements. The af orementioned IARs will report their TWG activities as an o utside business activity. For the avoidance of doubt, GGS does not recommend or select any other Advisors f or their Clients. The relationship with TWG is temporary until all Client accounts can be moved to GGS. Clients who still have advisory agreements with TWG will continue to pay management f ees directly to TWG, not GGS, until an advisory agreement is completed with GGS. At such time, the management f ee will be paid to GGS. GGS does not receive any compensation directly f rom TWG. 18  Item 11. Code of Ethics GGS has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets f orth the standards of conduct expected of its Supervised Persons. GGS’ Code of Ethics states that GGS owes a f iduciary duty to its clients, and contains written policies reasonably designed to prevent certain unlawf ul practices such as the use of material non-public inf ormation by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of GGS’ personnel (called “Access Persons”) to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public of f erings, limited of f erings). However, GGS Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a manner consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in suf f iciently broad markets to permit transactions by Access Persons to be completed without any appreciable impact on the markets of such securities. Theref ore, under certain limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client where there may be a potential f or conf lict, no Access Person may knowingly ef f ect f or themselves or f or their immediate f amily (i.e., spouse, minor children and adults living in the same household as the Access Person) a transaction in that security unless: the transaction has been completed; • the transaction f or the Access Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction f or the client. • These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certif icates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual f unds or money market f unds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual f unds. GGS shall provide a copy of its Code of Ethics to any clients and prospective clients upon request. 22 19  Item 12. Brokerage Practices GGS recommends that clients utilize the brokerage and clearing services of Fidelity Institutional Wealth Services (“Fidelity”) f or investment management accounts. GGS is independently owned and operated and not af f iliated with Fidelity. While we recommend that you use Fidelity as custodian/broker, you will decide whether to do so and open your account with Fidelity by entering into account agreement directly with t hem. GGS does not open the account f or you. Even though your account is maintained at Fidelity , we can still use other brokers to execute trades f or your account as described below (see “your brokerage and custody costs”) Factors which GGS considers in recommending Fidelity or any other broker-dealer to clients include their respective f inancial strength, reputation, execution, pricing, research and service. Fidelity enables GGS to obtain many mutual f unds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction f ees charged by Fidelity may be higher or lower than those charged by other Financial Institutions. The commissions paid by GGS’ clients comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualif ied Financial Institution might charge to ef f ect the same transaction where GGS determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative f actor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the f ull range of a Financial Institution’s services, including among othe rs, the value of research provided, execution capability, commission rates and responsiveness. GGS seeks competitive rates but may not necessarily obtain the lowest possible commission rates f or client transactions. GGS periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may direct GGS in writing to use a particular Financial Institution to execute some or all transactions f or the client. In that case, the client will negotiate terms and arrangements f or the account with that Financial Institution and the Firm will not seek better execution services or prices f rom other Financial Institutions or be able to “batch” client transactions f or ex ecution through other Financial Institutions with orders f or other accounts managed by GGS (as described below). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less f avorable net prices, on transactions f or the account than would otherwise be the case. Clients that direct their brokerage should also be aware that GGS will generally place such trades af ter the completion of trades f or clients that do not direct their brokerage. Subject to its duty of best execution, GGS may decline a client’s request to direct brokerage if , in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational dif f iculties or violate restrictions imposed by other broker-dealers (as f urther discussed below). 20  Consistent with our f iduciary responsibility of investing in the client’s best interest and within the client’s risk parameters, in exchange f or investing in certain exchange traded f unds and/or mutual f unds, GGS may receive investment research products and/or services which assist GGS in its investment decision- making process. Such research generally will be used to service all of the Firm’s clients, but f und expenses paid by one client may be used to pay f or research that is not used in managing that client’s portf olio. The receipt of investment research products and/or services as well as the allocation of the benef it of such investment research products and/or services poses a conf lict of interest because GGS does not have to produce or pay f or the products or services. The receipt of investment research products and/or services as well as the allocation of the benef it of such investment research products and/or services poses a conf lict of interest because GGS does not have to produce or pay f or the products or services. Software and Support Provided by Financial Institutions GGS may receive f rom Fidelity, without cost to GGS, computer sof tware and related systems support, which allow GGS to better monitor client accounts maintained at Fidelity. GGS may receive the sof tware and related support without cost because GGS renders investment management services to clients that maintain assets at Fidelity. The sof tware and support is not provided in connection with securities transactions of clients (i.e., not “sof t dollars”). The sof tware and related systems support may benef it GGS, but not its clients directly. In f ulf illing its duties to its clients, GGS endeavors at all times to put the interests of its clients f irst. Clients should be aware, however, that GGS’ receipt of economic benef its from a broker- dealer creates a conf lict of interest since these benef its may inf luence GGS’ choice of broker-dealer over another broker-dealer that does not f urnish similar sof tware, systems support or services. Additionally, GGS may receive the f ollowing benef its f rom Fidelity through the Fidelity Institutional Wealth Services Group: receipt of duplicate client conf irmations and bundled duplicate statements; access to a trading desk; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network f or client order entry and account inf ormation. Fidelity WAS Program GGS has entered into an agreement with Fidelity to participate in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which GGS receives ref errals f rom Strategic Advisers LLC (“Strategic Advisers”), a registered investment adviser and Fidelity Investments company. GGS pays a f ee to participate in the WAS Program. GGS’s participation in the WAS program raises conf licts of interest. Pursuant to the agreement, GGS has agreed not to solicit clients to transf er their brokerage accounts f rom af f iliates of Strategic Advisers or establish brokerage accounts at other custodians f or ref erred clients other than when GGS’s f iduciary duties would so require, and GGS has agreed to pay Strategic Advisers a one - time f ee equal to 0.75% of the assets in a client account that is transf erred f rom Strategic Adviser’s af f iliates to another custodian; theref ore, GGS has an incentive to suggest that ref erred clients and their household members maintain custody of their accounts with af f iliates of Strategic Ad visers. However, participation in the WAS Program does not limit GGS’s duty to select brokers on the basis of best execution. 21  Trade Aggregation Transactions f or each client will be ef f ected independently, unless GGS decides to purchase or sell the same securities f or several clients at approximately the same time. GGS may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more f avorable commission rates or to allocate equitably among the Firm’s clients dif f erences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among GGS’ clients pro rata to the purchase and sale orders placed f or each client on any given day. To the extent that the Firm determines to aggregate client orders f or the purchase or sale of securities, including securities in which GGS’ Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staf f of the U.S. Securities and Exchange Commission. GGS does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant f actors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portf olios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it f rom purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unf oreseen changes in an account’s assets af ter an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) f rom the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis Mutual Fund Share Class Selection Mutual Funds generally of fer multiple share classes available f or investment based upon certain eligibility and/or purchase requirements. For instance, in addition to retail share classes (typically ref erred to as class A, class B and class C shares), f und s may also of fer institutional share classes or other share classes that are specif ically designed f or purchase by investors who meet certain specif ied eligibility criteria, including, f or example, whether an account meets certain minimum dollar amount. Institutional share classes usually have a lower expense ratio than other share classes. When recommending investments in mutual f unds, it is our policy to review and consider available share classes. Our policy is to select the most appropriate share classes based on various f actors including but not limited to: minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability and other f actors. When considering all the appropriate f actors, we can select a s hare class other than the ‘lowest cost’ share class. In order to select the most appropriate share class, we consider retail, institutional or other share classes of the same mutual f und. Regardless of such considerations, clients should not assume that th ey will be 22  invested in the share class with the lowest possible expense ratio. Clients should ask their adviser whether a lower cost share class is available instead of those selected by GGS. GGS periodically reviews the mutual f unds held in client accounts to select the most appropriate share classes in light of its duty to obtain best execution. 23  Item 13. Review of Accounts Account Reviews For those clients to whom GGS provides investment management services, GGS monitors those portf olios as part of an ongoing process while regular account reviews are conducted on at least a quarterly basis. For those clients to whom GGS provides f inancial planning and/or consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one of GGS’ investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with GGS and to keep GGS inf ormed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting f rom any changes in the client’s f inancial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction conf irmation notices and regular summary account statements directly f rom the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports f rom GGS and/or an outside service provider, which contain certain account and/or market-related inf ormation, such as an inventory of account holdings or account perf ormance. Clients should compare the account statements they receive f rom their custodian with those they receive f rom GGS or an outside service provider. Those clients to whom GGS provides financial planning services will receive reports f rom GGS summarizing its analysis and conclusions as requested by the client or as otherwise agreed to in writing by GGS. 24  Item 14. Client Referrals and Other Compensation Fidelity Wealth Advisors Solutions® Program GGS has entered into an agreement with Fidelity to participate in the Fidelity Wealth Advisor Solutions ® Program (the “WAS Program”), through which GGS receives ref errals f rom Strategic Advisers LLC (“Strategic Advisers”), a registered investment adviser and Fidelity Investments company. GGS is independent and not af f iliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control GGS, and Strategic Advisers has no responsibility or oversight for GGS’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor f or GGS, and the Firm pays ref erral f ees to Strategic Advisers f or each ref erral received based on the Firm’s assets under management attributable to each client ref erred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors f ind an independent investment adviser, and any ref erral f rom Strategic Advisers to GGS does not constitute a recommendation by Strategic Advisers of GGS’s particular investment management services or strategies. Under this arrangement, GGS pays the f ollowing amounts to Strategic Advisers f or ref errals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identif ied as “f ixed income” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, GGS has agreed to pay Strategic Advisers an annual program f ee of $50,000 to participate in the WAS Program. These ref erral f ees are paid in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirement. Furthermore, these ref erral f ees are paid by GGS and does not result in any additional charge to the client. At the time of the ref erral, Strategic Advisers will disclose that they are not a current client of GGS; they will receive cash compensation f or the ref erral; and the receipt of compensation f or a ref erral creates a conf lict of interest. In addition, Strategic Advisers will provide prospective client with a copy of a written disclosure statement disclosing the terms and conditions of the arrangement between GGS and Strategic Advisers including the compensation Strategic Advisers will receive f rom GGS and any material conf licts of interest on the part of Strategic Advisers as a result of the ref erral arrangement. To receive ref errals f rom the WAS Program, GGS must meet certain minimum participation criteria, but GGS may have been selected f or participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its af f iliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, GGS has a conf lict of interest with respect to its decision to use certain af f iliates of Strategic Advisers, including FBS, f or execution, custody and clearing f or certain client accounts, and GGS has an incentive to suggest the use of FBS and its af f iliates to its advisory clients, whether or not those clients were ref erred to GGS as part of the WAS Program. Under an agreement with Strategic Advisers, GGS has agreed that it will not charge clients more than the standard range of advisory f ees disclosed in this brochure to cover solicitation f ees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, GGS has agreed not to solicit clients to transf er their brokerage accounts 25  f rom af f iliates of Strategic Advisers or establish brokerage accounts at other custodians f or ref erred clients other than when GGS’s f iduciary duties would so require, and GGS has agreed to pay Strategic Advisers a one-time f ee equal to 0.75% of the assets in a client account that is transf erred f rom Strategic Adviser’s af f iliates to another custodian; theref ore, GGS has an incentive to suggest that ref erred clients and their household members maintain custody of their accounts with af f iliates of Strategic Advisers. However, participation in the WAS Program does not limit GGS’s duty to select brokers on the basis of best execution. Other Economic Benefit GGS receives economic benef its f rom Fidelity f or providing advice or other advisory services to clients. This type of relationship poses a conf lict of interest and any such relationship is disclosed in response to Item 12, above. Receipt of Insurance Commission The Firm and its Supervised Persons receive insurance commissions on Long Term Care sold in the past. However, GGS’ Supervised Persons are no longer licensed insurance agents, we do not recommend the purchase of certain insurance products to advisory clients on a commission basis. 26  Item 15. Custody GGS is deemed to have custody over a client’s assets when it is authorized to directly debit a client’s account f or payment of the GGS’s f ee. GGS’ Agreement and/or the separate agreement with any Financial Institution may authorize GGS through such Financial Institution to debit the client’s account f or the amount of GGS’ f ee and to directly remit that management f ee to GGS in accordance with applicable custody rules. The Financial Institutions recommended by GGS have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed f rom the account including the amount of management f ees paid directly to GGS. In addition, as discussed in Item 13, GGS also sends periodic supplemental reports to clients. Clients should caref ully review the statements sent directly by the Financial Institutions and compare them to those received f rom GGS. Item 16. Investment Discretion GGS may be given the authority to exercise discretion on behalf of clients. GGS is considered to exercise investment discretion over a client’s account if it can ef f ect transactions f or the client without f irst having to seek the client’s consent. GGS is given this authority through a power-of -attorney included in the agreement between GGS and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). GGS takes discretion over the f ollowing activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or f ired. 27  Item 17. Voting Client Securities GGS is required to disclose if it accepts authority to vote client securities. GGS does not vote client securities on behalf of its clients. Clients receive proxies directly f rom the Financial Institutions. Item 18. Financial Information GGS is not required to disclose any f inancial inf ormation pursuant to this Item due to the f ollowing: • The Firm does not require or solicit the prepayment of more than $1,200 in f ees six months or more in advance of services rendered; • The Firm does not have a f inancial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. 28  Galvin, Gaustad & Stein, LLC Disclosure Brochure GALVIN ■ GAUSTAD ■ STEIN LLC. WEALTH MANAGEMENT 29 

Galvin, Gaustad & Stein, LLC Wrap Brochure Wrap Fee Program Brochure December 24, 2025 This Wrap Brochure provides inf ormation about the qualif ications and business practices of Galvin, Gaustad & Stein, LLC (hereinaf ter “GGS” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at (480) 776-1445. The inf ormation in this brochure has not been approved or verif ied by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional inf ormation about the Firm is available on the SEC’s website at www.adviserinf o.sec.gov. GGS is an investment adviser registered with the SEC under the investment Advisers Act of 1940, as amended (the “Advisers Act”), however, such registration does not imply a certain level of skill or training . 7377 East Doubletree Ranch Road, Suite 250, Scottsdale, Arizona 85258 | (480) 776-1445 www.GGSAdvisors.com 1  Item 2. Material Changes In this Item, GGS is required to discuss any material changes that have been made to the brochure since the last annual amendment f iled March 28, 2025. Item 9 has been updated to ref lect the addition of Other Financial Industry Activities and Af f iliations. Item 3. Table of Contents Item 1. Cover Page ............................................................................................................................................... 1 Item 2. Material Changes ........................................................................................................................................ 2 2  Item 3. Table of Contents ........................................................................................................................................ 2 Item 4. Services, Fees and Compensation................................................................................................................ 4 Item 5. Account Requirements and Types of Clients ................................................................................................. 7 Item 6. Portfolio Manager Selection and Evaluation................................................................................................... 7 Item 7. Client Inf ormation Provided to Portf olio Managers........................................................................................ 13 Item 8. Client Contact with Portfolio Managers ........................................................................................................ 13 Item 9. Additional Inf ormation ................................................................................................................................ 13 3  Item 4. Services, Fees and Compensation The Galvin, Gaustad & Stein Wrap Fee Program (the “Program”) is an investment advisory program sponsored by GGS, a wealth management f irm that has been serving its clients since 2010. This Wrap Fee Program Brochure describes the Program of f ered by GGS and the business of GGS as it relates to clients receiving services through the Program. Certain sections also discuss the activities of its Supervised Persons, which ref er to the Firm’s of ficers, partners, directors (or other persons occupying a similar status or perf orming similar f unctions), employees or any other person who provides invest ment advice on GGS’ behalf and is subject to the Firm’s supervision or control. Other advisory services of f ered by GGS are described in another brochure, GGS Disclosure Brochure, which contains the inf ormation required by Part 2A of Form ADV. Description of the Program The Program provides clients with investment management services and the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. GGS is the sponsor and the portfolio manager of the Program. Generally, clients participating in the Program (“Wrap Program Clients”) pay this single, all-inclusive f ee that includes money management f ees, certain transaction costs, and custodial and administrative costs. GGS receives a portion of the wrap f ee f or its services as the portf olio management to the Program as well as the sponsor of the Program. Transactions f or your account are executed by a securities broker-dealer via the Program. Prior to receiving services through the Program, clients are required to enter into a written agreement with GGS setting f orth the relevant terms and conditions of the advisory relationship (the “Agreement”). Clients must also open a new securities brokerage account and complete a new account agreement with Fidelity Institutional Wealth Services (“Fidelity”) or another broker-dealer GGS approves under the Program (collectively “Financial Institutions”). Fees for Participation in the Program GGS provides investment management services under the Program Clients in the Program pay GGS a single, all inclusive, annual f ee based on the portf olio value of the assets under the Firm’s management. The f ee varies based on the f ollowing linear f ee schedule(s): Discretionary Services PORTFOLIO VALUE ANNUAL FEE $0 - $500,000 1.25% $500,001 – $2,500,000 1.00% $2,500,001 - $5,000,000 0.80% More than $5,000,000 Negotiable Non-Discretionary Services 4  PORTFOLIO VALUE ANNUAL FEE $0 - $500,000 1.50% $500,001 – $2,500,000 1.25% $2,500,001 - $5,000,000 1.05% More than $5,000,000 Negotiable The annual f ee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by GGS on the last day of the previous billing quarter. The Firm includes cash in a clients account in determining the valuation f or billing purposes. The Firm may, in its sole discretion, not include cash in determining the f ee, especially where a client has a high percentage of cash f or reasons other than the Firm's investment management decision. If assets are deposited into or withdrawn f rom an account af ter the inception of a billing period, the f ee payable with respect to such assets is adjusted to ref lect the change in portf olio value. For the initial term of an engagement, the f ee is calculated on a pro rata basis. In the event the Agreement is terminated, the f ee f or the f inal billing period is prorated through the ef f ective date of the termination and the unearned portion is ref unded to the client. For clients who engage the Firm f or non-discretionary services, the Firm of f ers an introductory period during which the Firm applies its f ee schedule f or its discretionary services. This introductory period is generally the f irst ninety (90) days of the engagement. Clients are advised that a conf lict of interest exists f or the Firm to recommend that clients engage GGS for additional services f or compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Fee Discretion GGS, in its sole discretion, may negotiate to charge a lesser f ee based upon certain criteria, such as anticipated f uture earning capacity, anticipated f uture additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities. Additional Fees and Expenses In addition to the advisory f ees paid to GGS, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other f inancial institutions. These additional charges include f ees attributable to alternative assets, reporting charges, margin costs, mark - ups or mark-downs priced in to f ixed income products by the broker-dealer, charges imposed directly by a mutual f und or ETF in a client’s account, as disclosed in the f und’s prospectus (e.g., f und management f ees and other f und expenses), f ees and commission f or assets not held with their custodian (such as 401(k) or 5  529 plan assets), def erred sales charges, odd -lot dif ferentials, transf er taxes, wire transf er and electronic f und f ees. Fee Debit Clients provide GGS with the authority to directly debit their accounts f or payment of the Firm’s investment advisory f ees. The Financial Institutions that act as qualif ied custodian f or client accounts have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to GGS. Alternatively, clients may elect to have GGS send them an invoice f or direct payment. Account Additions and Withdrawals Clients may make additions to and withdrawals f rom their account at any time, subject to GGS’ right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transf erred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to GGS, subject to the usual and customary securities settlement procedures. However, GGS designs its portf olios as long -term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. GGS may consult with its clients about the options and implications of transf erring securities. Clients are advised that when transf erred securities are liquidated, they may be subject to transaction f ees, f ees assessed at the mutual f und level (i.e. contingent def erred sales charge) and/or tax ramif ications. Fee Comparison A portion of the f ees paid to GGS are used to cover the securities brokerage commissions and transactional costs. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, the commissions charged f or each transaction, and other transaction costs determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate f ee f or advisory services. Fees paid f or the Program may also be higher or lower than f ees charged by other sponsors of comparable investment advisory programs. Because the Firm pays f or the brokerage f ees, the Firm has an incentive to engage in less transactions, or transactions that cost less to the Firm—including the use of mutual f unds that do not have transaction charges but have higher expenses to the client The Firm reviews the f requency and type of investments made in client accounts to act in the client’s best interest. Compensation for Recommending the Program GGS has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. 6  Item 5. Account Requirements and Types of Clients GGS provides its services to individuals, trusts, pension and prof it sharing plans, and corporations and other business entities. Minimum Portfolio Size As a condition f or starting and maintaining an investment management relationship, GGS imposes a minimum portf olio size of $500,000. The Firm, in its sole discretion, may accept clients with smaller portf olios based upon certain criteria, such as anticipated f uture earning capacity, anticipated f uture additional assets, dollar amount of assets to be managed, related accounts, account co mposition, pre- existing client relationships, account retention and pro bono activities. GGS only accepts clients with less than the minimum portf olio size if , in the sole opinion of the Firm, the smaller portf olio size will not result in a substantial increase of investment risk beyond the client’s identif ied risk tolerance. GGS may aggregate the portf olios of f amily members to meet the minimum portf olio size. Item 6. Portfolio Manager Selection and Evaluation GGS acts as the sponsor and sole portf olio manager under the Program; as such, investment management services are provided directly by the Firm. Investment management services generally include a broad range of f inancial planning services as well as discretionary and/or non-discretionary management of investment portf olios. Financial Planning Services Financial planning services, which may include any or all of the f ollowing f unctions: Investment Consulting • Business Planning • Insurance Needs Analysis • Cash Flow Forecasting • • Asset Allocation • Retirement Plan Analysis • Retirement Planning • Charitable Giving • Estate Planning • Risk Management • Financial Reporting • Distribution Planning 7  Management of Investment Portfolios GGS primarily allocates client assets among individual debt and equity securities and exchange -traded f unds (“ETFs”), in accordance with the investment objectives of its individual clients. On a more limited basis, the Firm allocates client assets among independent investment managers (“Independent Managers”) and options, as well as the securities components of variable annuities and variable lif e insurance contracts. In addition, GGS may also recommend that clients who qualif y as accredited investors, as def ined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge f unds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portf olios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specif ically agreed upon. Clients may also engage GGS to advise on certain investment products that are not maintained at their primary custodian, such as variable lif e insurance and annuity contracts and assets held in employer sponsored retirement plans and qualif ied tuition plans (i.e., 529 plans). In these situations, GGS directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. GGS tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portf olios are managed in a manner consistent with their specif ic investment prof iles. GGS consults with clients on an initial and ongoing basis to determine their specif ic risk tolerance, time horizon, liquidity constraints and other qualitative f actors relevant to the management of their portf olios. Clients are advised to promptly notif y GGS if there are changes in their f inancial situation or if they wish to place any limitations on the management of their portf olios. Clients may impose reasonable restrictions or mandates on the management of their accounts if GGS determines, in its sole discretion, the conditions would not materially impact the perf ormance of a management strategy or prove overly burdensome to the Firm’s management ef f orts. Performance-Based Fees and Side-By-Side Management GGS does not provide any services f or a perf ormance-based f ee (i.e., a f ee based on a share of capital gains or capital appreciation of a client’s assets). 8  Methods of Analysis and Investment Strategies GGS has developed a propriety security selection methodology based primarily on f undamental analysis. Fundamental analysis involves an evaluation of the f undamental f inancial condition and competitive position of a particular f und or issuer. For individual equities, GGS’ process typically involves three primary components: (1) A stock screening process based on academic studies and GGS research, which highlights quantitative metrics that historically have led to long-term, risk-adjusted outperf ormance. Examples include f avoring stocks with low volatility, consistent dividend growth, strong profitability and solid earnings quality. (2) A company-specific discounted cash f low model to determine our f air value estimate f or a company’s stock price based on a combination of GGS and sell-side consensus f orecasts. GGS believes the best valuation method is to discount a company’s expected f uture cash f lows at an appropriate discount rate based on risk. (3) A deep - dive qualitative analysis of the company f ocusing on items such as: i) competitive advantages that support revenue growth, margins and returns on capital; ii) shareholder-f riendly management teams with strong track records; iii) red f lags such as high customer, supplier, geographic or shareholder concentration, lawsuits, debt or accounting issues; and iv) recent news and upcoming potential catalyst events. Stocks that look most f avorable to GGS based on all three of the above selection tests have a high likelihood of being purchased in client portf olios, subject to individual client suitability, cash availability and portf olio risk constraints. For individual bond selection, GGS f ocuses its research on the f inancial health of the issuer including debt levels, debt covenants, payment schedules and GGS’ belief in the company’s ability to repay the particular bond the Firm is buying f or clients. GGS primarily invests in the individual company debt of investment grade corporations. GGS attempts to maximize yield while minimizing both interest rate and credit risk, as well as making sure the security f its in the client’s overall portf olio from a risk and diversif ication standpoint. For mutual f unds and ETFs, GGS’ research process typically involves an analysis of the security’s expense ratio, total assets and trading liquidity as well as the issuer’s management team, style drif t, past perf ormance, reputation and f inancial strength. A substantial risk in relying upon f undamental analysis is that while the overall health and position of a company or f und may be good, evolving market conditions may negatively impact the security. GGS develops individual investment strategies based upon each client’s specif ic risk prof ile and investment objectives. As discussed above, the Firm employs an analytical approach based upon f undamental analysis. GGS generally seeks to target individual stocks and bonds, and ETFs, which are designed to achieve each client’s stated goals. Risks of Loss General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear potential losses. Past perf ormance is in no way an indication of f uture results. Over time, assets will f luctuate and be worth more or less than the initial invested amount. Depending on the investment type, dif f ering risk levels will exist. 9  GGS cannot of f er any guarantees or promises that a client's f inancial goals and objectives will be met. GGS does not represent or guarantee that any services provided or analysis methods can predict f uture results, successf ully identif y market tops or bottoms, or insulate clients f rom losses due to market corrections or declines. Clients are advised that certain assumptions may be made regarding interest and inf lation rates, past trends, and the perf ormance of the market and economy. There is no guarantee o f client account f uture perf ormance or any level of perf ormance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual perf ormance shown will lead to expected results or perf o rm in any predictable manner. When evaluating risk, f inancial loss may be viewed dif f erently by each client and may depend on many dif f erent risks, each of which may af f ect the probability and magnitude of potential losses. The f ollowing list of investment risks, which is not all-inclusive, is provided f or caref ul consideration by a prospective client bef ore retaining our services or contemplating investments in general. (Please note: The below items are presented not in order of importance.) Market Risks Market risk involves the possibility that an investment's current market value will f all because of a general market decline, reducing the investment value regardless of the issuer's operational success or f inancial condition. The price of a security, optio n, bond, or mutual f und can drop due to tangible and intangible events and situations. External f actors cause this risk, independent of a security's underlying circumstances. The prof itability of a signif icant portion of GGS’ recommendations may depend to a great extent upon correctly assessing the f uture course of price movements of stocks and bonds. There can be no assurance that GGS will be able to predict those price movements accurately. Bank Obligations Risks Bank Obligations including bonds and certif icates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other f inancial institutions are af f ected by interest rates and may be adversely af f ected by downturns in the US and f oreign economies or banking regulations changes. Bankruptcy Risks Bankruptcy of a broker or custodian could cause excessive costs or loss of investor funds. If a broker with which the Advisor has an account becomes insolvent or bankrupt, the Advisor may be unable to recover all or even a portion of the assets maintained by clients with that broker. Similarly, if a c ustodian housing a client’s securities or other assets becomes bankrupt or insolvent, the client may be unable to recover all or even a portion of the assets held by the custodian. Conflicts of Interest Risks In administering client portf olios and f inancial reporting, advisers f ace inherent interest conf licts. They mitigate these conf licts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client’s interest is always held above that of the f irm and its Associates. 10  Cybersecurity Risks GGS and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data f rom both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage or interruption f rom computer viruses, network f ailures, computer and telecommunications f ailures, inf iltration by unauthorized persons and security breaches, usage errors by their respective prof essionals, power outages and catastrophic events such as f ires, tornadoes, f loods, hurricanes and earthquakes. A cybersecurity breach could expose both GGS and its clients’ accounts to substantial costs (including, without limitation, those associated with f orensic analysis of the origin and scope of the breach, i ncreased and upgraded cybersecurity, identity thef t, unauthorized use of proprietary inf ormation, litigation, adverse investor reaction, the dissemination of conf idential and proprietary inf ormation and reputational damage), civil liability as well as regulatory inquiry and/or action. While GGS has established a business continuity plan in the event of , and risk management strategies, systems, policies and procedures to seek to prevent, cybersecurity breaches, there are inherent limitations in such plans, strategies, systems, policies and proced ures including the possibility that certain risks have not been identif ied. Furthermore, GGS cannot control the cybersecurity plans, strategies, systems, policies and procedures put in place by other service providers and/or the issuers in which GGS invests. Artif icial Intelligence Engines and Machine Learning (collectively “AI”) AI is used as an umbrella term that encompasses a broad spectrum of dif f erent technologies and applications. GGS def ines AI as computer systems able to perf orm tasks that normally require human intelligence, such as visual perception, speech recognition, d ecision-making, and translation between languages, more commonly known as generative AI. As part of our investment management process the Firm uses AI, in part but not exclusively, as part of its investment, research, clerical or due diligence processes. When relying on AI there are certain risks involved, including data quality, copyright and trade secret violations, conf identiality breaches, unauthorized access or malware risks, insider trading, breach of contract, cybersecurity, and privacy law violatio ns. Data inputs and outputs are assessed and evaluated for data integrity, however, there is no assurance of accuracy, and your account may be negatively af f ected. Diversification and Concentration Concentrating investments in a single industry may result in losses due to f actors that af f ect an entire industry. Each particular industry or sector may be af f ected by unique risks, and the value of investments in a particular industry will dif f er f rom the value of the overall stock market. Fluctuations in specif ic market sectors are of ten more extreme than f luctuations in the overall market. Theref ore, concentrating investments in a single industry exposes an investor to the risk that a single set of events or circumstances will decrease the value of the investor’s overall portf olio. 11  Inflation & Interest Rate Risk Security prices and portf olio returns will likely vary in response to inf lation and interest rates changes. Inf lation causes f uture dollars to be worth less and may reduce the purchasing power of a client's f uture interest payments and principal. Inf latio n also generally leads to higher interest rates which may cause the value of many types of f ixed-income investments to decline. Equity Equity Investment Risk - generally ref ers to buying shares of stocks by an individual or f irm in return for receiving a f uture payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Mutual Funds and ETFs An investment in a mutual f und or ETF involves risk, including the loss of principal. Mutual f und and ETF shareholders are necessarily subject to the risks stemming f rom the individual issuers of the f und’s underlying portf olio securities. Such shareholders are also liable f or taxes on any f und-level capital gains, as mutual f unds and ETFs are required by law to distribute capital gains in the event they sell securities for a prof it that cannot be of f set by a corresponding loss. Shares of mutual f unds are generally distributed and redeemed on an ongoing basis by the f und itself or a broker acting on its behalf . The trading price at which a share is transacted is equal to a f und’s stated daily per share net asset value (“NAV”), plus any shareholders f ees (e.g., sales loads, purchase f ees, redemption f ees). The per share NAV of a mutual f und is calculated at the end of each business day, although the actual NAV f luctuates with intraday changes to the market value of the f und’s holdings. The trading prices of a mutual f und’s shares may dif f er signif icantly f rom the NAV during periods of market volatility, which may, among other f actors, lead to the mutual f und’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily f or indexed based ETFs and more f requently f or actively managed ETFs. However, certain inef f iciencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market f or such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Theref ore, if a liquid secondary market ceases to exist f or shares of a particular ETF, a shareholder may have no way to dispose of such shares. Bonds – Inflation Risk Inf lation risk results f rom the variation in the value of cash f lows f rom a security due to inf lation, as measured in terms of purchasing power. For example, if a client purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate of inf lation is 6%, then the purchasing power of the cash f low has declined. For all but inf lation linked bonds, adjustable bonds or f loating rate bonds, clients are exposed to inf lation risk because the interest rate the issuer promises to make is f ixed f or t he lif e of the security. To the extent that interest rates ref lect the expected inf lation rate, f loating rate bonds have a lower level of inf lation risk. 12  Corporate Bond Risks Corporate debt securities (or "bonds") are typically saf er investments than equity securities, but their risk can also vary widely based on: the f inancial health of the issuer; the risk that the issuer might def ault; when the bond is set to mature; and, whether or not the bond can be "called" bef ore maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Options Risks Options allow investors to buy or sell a security at a contracted strike price (not necessarily the current market price) at or within a specif ic period of time. Clients may pay or collect a premium f or buying or selling an option. Investors transact in options to either hedge against potential losses or to speculate on the perf ormance of the underlying securities. Option transactions involve inherent risks, including the partial or total loss of principal in the event that the value of the underlying security or index does not increase or decrease to the level of the respective strike price. Holders of option contracts are also subject to def ault by the option writer which may be unwilling or unable to perf orm its contractual obligations. Use of Independent Managers GGS may recommend the use of Independent Managers. In these situations, GGS continues to do ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, GGS generally may not have the ability to supervise the Independent Managers on a day -to-day basis. Voting Client Securities GGS is required to disclose if it accepts authority to vote client securities. GGS does not vote client securities on behalf of its clients. Clients receive proxies directly f rom the Financial Institutions. Item 7. Client Information Provided to Portfolio Managers In this Item, GGS is required to describe the inf ormation about clients that the Firm communicates to the clients’ portf olio managers. GGS has no disclosures to make pursuant to this Item because the Firm acts as the sponsor and sole portf olio manager under the Program. Item 8. Client Contact with Portfolio Managers There are no restrictions on a client’s ability to contact and consult with GGS. Item 9. Additional Information Disciplinary Information GGS has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. 13  Other Financial Industry Activities and Affiliations Receipt of Insurance Commission The Firm and its Supervised Persons receive insurance commissions on Long Term Care sold in the past. However, GGS’ Supervised Persons are no longer licensed insurance agents, we do not recommend the purchase of certain insurance products to advisory clients on a commission basis. Dual Registered Investment Adviser Representatives Certain of GGS’s Management Persons are dual registered with another state registered investment advisor. GGS has two IARs, David G. Millet and Vincent E. Westerman, who are dually registered with GGS and The Westerman Group, LLC, (TWG) an Ohio state Regis tered Investment Advisor. The purpose of this dual registration is to f acilitate the transf er of clients f rom TWG to GGS as part of a planned integration of the two f irms. The dual registration is set up so that Mr. Millet and Mr. Westerman can ef f ectively manage each f irm’s respective Client assets while Client accounts are moved f rom TWG to GGS. This process is expected to be completed by April 1, 2026. There is a conf lict in that these IARs will be collecting a management f ee f rom Clients that currently have an advisory relationship with TWG as well as Clients who have signed new advisory agreements with GGS. Both IARs will also be responsible f or f ollowing each respective f irm’s code of ethics and reporting requirements. GGS believes that it has remediated these conf licts by having a planned transition timeline f or existing Clients of TWG to sign new advisory agreements with GGS. Af ter the transition of all TWG Clients to GGS, TWG will withdraw its registration f rom the state of Ohio and decommission TWG. At such point, they will be IARs exclusively to GGS. Since TWG Clients will eventually be GGS Clients, there is a presumption that GGS and TWG have a vested interest in maintaining their f iduciary duties to each Client wit hout f avoring either TWG or GGS Clients. Both f irm’s Clients will either continue to or have access to GGS’s investment program. Each f irm will be responsible f or overseeing its code of ethics. There is not expected to be any conf lict in reporting requirements. The af orementioned IARs will report their TWG activities as an outside business activity. For the avoidance of doubt, GGS does not recommend or select any other Advisors f or their Clients. The relationship with TWG is temporary until all Client accounts can be moved to GGS. Clients who still have advisory agreements with TWG will continue to pay management f ees directly to TWG, not GGS, until an advisory agreement is completed with GGS. At such time, the management f ee will be paid to GGS. GGS does not receive any compensation directly f rom TWG. Code of Ethics GGS has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets f orth the standards of conduct expected of its Supervised Persons. GGS’ Code of Ethics contains written policies reasonably designed to prevent certain unlawf ul practices such as the use of material non-public inf ormation by the Firm or any of its Supervised Persons and the trading by the same of securities ahead 14  of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of GGS’ personnel (called “Access Persons”) to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public of f erings, limited of f erings). However, GGS Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a manner consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in suf f iciently broad markets to permit transactions by Access Persons to be completed without any appreciable impact on the markets of such securities. Theref ore, under certain limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client where there may be a potential f or conf lict, no Access Person may knowingly ef f ect f or themselves or f or their immediate f amily (i.e., spouse, minor children and adults living in the same household as the Access Person) a transaction in that security unless: the transaction has been completed; • the transaction f or the Access Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction f or the client. • These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certif icates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual f unds or money market f unds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual f unds. GGS shall provide a copy of its Code of Ethics to any clients and prospective clients upon request. Account Reviews GGS monitors investment management portf olios as part of an ongoing process while regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by one of GGS’ investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with GGS and to keep GGS inf ormed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting f rom any changes in the client’s f inancial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction conf irmation notices and regular summary account statements directly f rom the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports f rom GGS and/or an outside service provider, which contain certain account and/or market-related inf ormation, such as an inventory of account holdings or account perf ormance. Clients should compare the account statements they receive f rom their custodian with those they receive f rom GGS or an outside service provider. 15  Client Referrals Participation in Fidelity Wealth Advisor Solutions® Program GGS has entered into an agreement with Fidelity to participate in the Fidelity Wealth Advisor Solutions ® Program (the “WAS Program”), through which GGS receives ref errals f rom Strategic Advisors LLC (“Strategic Advisors”), a registered investment adviser and Fidelity Investments company. GGS is independent and not af f iliated with Strategic Advisors or any Fidelity Investments company. Strategic Advisors does not supervise or control GGS, and Strategic Advisors has no responsibility or oversight for GGS’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisors acts as a solicitor f or GGS, and the Firm pays ref erral f ees to Strategic Advisors f or each ref erral received based on the Firm’s assets under management attributable to each client ref erred by Strategic Advisors or members of each client’s household. The WAS Program is designed to help investors f ind an independent investment adviser, and any ref erral f rom Strategic Advisors to GGS does not constitute a recommendation by Strategic Advisors of GGS’s particular investment management services or strategies. More specif ically, GGS pays the f ollowing amounts to Strategic Advisors f or ref errals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identif ied as “f ixed income” assets by Strategic Advisors and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, GGS has agreed to pay Strategic Advisors an annual f ee of $50,000 to participate in the WAS Program. These ref erral f ees are paid in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. Furthermore, these ref erral f ees are paid by GGS and does not result in any additional charge to the client. At the time of the ref erral, Strategic Advisors will disclose that they are not a current client of GGS; they will receive cash compensation f or the ref erral; and the receipt of compensation f or a ref erral creates a conf lict of interest. In addition, Strategic Advisors will provide prospective client with a copy of a written disclosure statement disclosing the terms and conditions of the arrangement between GGS and Strategic Advisors including the compensation Strategic Advisors will receive f rom GGS and any material conf licts of interest on the part of Strategic Advisors as a result of the ref erral arrangement. To receive ref errals f rom the WAS Program, GGS must meet certain minimum participation criteria, but GGS may have been selected f or participation in the WAS Program as a result of its other business relationships with Strategic Advisors and its af f iliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, GGS has a conf lict of interest with respect to its decision to use certain af f iliates of Strategic Advisors, including FBS, f or execution, custody and clearing f or certain client accounts, and GGS has an incentive to suggest the use of FBS and its af f iliates to its advisory clients, whether or not those clients were ref erred to GGS as part of the WAS Program. Under an agreement with Strategic Advisors, GGS has agreed that it will not charge clients more than the standard range of advisory f ees disclosed in this brochure to cover solicitation f ees paid to Strategic Advisors as part of the WAS Program. Pursuant to these arrangements, GGS has agreed not to solicit clients to transf er their brokerage accounts f rom af f iliates of or establish brokerage accounts at other custodians f or ref erred clients other than when GGS’s f iduciary duties would so require, and GGS has agreed to pay Strategic Advisors a one- time f ee equal to 0.75% of the assets in a client account that is transf erred f rom Strategic Advisors’ af f iliates to another custodian; theref ore, GGS has an incentive to suggest that ref erred clients and their household members maintain custody of their accounts with af f iliates of Strategic Advisors. However, participation in 16  the WAS Program does not limit GGS’s duty to select brokers on the basis of best execution. Receipt of Economic Benefit GGS receives f rom Fidelity, without cost to GGS, computer sof tware and related systems support, which allow GGS to better monitor client accounts maintained at Fidelity. GGS receives the sof tware and related support without cost because GGS renders investment management services to clients that maintain assets at Fidelity. The sof tware and support is not provided in connection with securities transactions of clients (i.e., not “sof t dollars”). The sof tware and related systems support may benef it GGS, but no t its clients directly. In f ulf illing its duties to its clients, GGS endeavors at all times to put the interests of its clients f irst. Clients should be aware, however, that GGS’ receipt of economic benef its f rom a broker-dealer creates a conf lict of interest since these benef its may inf luence GGS’ choice of broker-dealer over another broker- dealer that does not f urnish similar sof tware, systems support or services. Additionally, GGS receives the f ollowing benef its f rom Fidelity through its Fidelity Institutional Wealth Services Group: receipt of duplicate client conf irmations and bundled duplicate statements; access to a trading desk; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network f or client order entry and account inf ormation. Trade Aggregation Transactions f or each client will be ef f ected independently, unless GGS decides to purchase or sell the same securities f or several clients at approximately the same time. GGS may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more f avorable commission rates or to allocate equitably among the Firm’s clients dif f erences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among GGS’ clients pro rata to the purchase and sale orders placed f or each client on any given day. To the extent that the Firm determines to aggregate client orders f or the purchase or sale of securities, including securities in which GGS’ Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staf f of the U.S. Securities and Exchange Commission. GGS does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant f actors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portf olios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it f rom purchasing other securities which are expected to produce similar investment results and c an be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unf oreseen changes in an account’s assets af ter an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or 17  more accounts, the Firm may exclude the account(s) f rom the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Financial Information GGS is not required to disclose any f inancial inf ormation pursuant to this Item due to the f ollowing: • The Firm does not require or solicit the prepayment of more than $1,200 in f ees six months or more in advance of services rendered; • The Firm does not have a f inancial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. 18  Galvin, Gaustad & Stein, LLC Wrap Brochure GALVIN ■ GAUSTAD ■ STEIN LLC. WEALTH MANAGEMENT 19